CORNELL UNIVERSITY
Cornell Institute for Social and Economic
Research Policy
POLICY
Volume: RD
CRADC Restricted Data
Security Breach Reporting
and Response Policy
Responsible Office:
Cornell Institute for
Social and Economic
Research
Responsible Executive:
CISER Secure Data
Services Manager
Originally Issued: 7/1/15
Revised:
POLICY STATEMENT
This policy establishes measures that must be taken to report and respond to a possible breach
or compromise of restricted data, including the determination of the systems affected, whether
any restricted data have in fact been compromised, what specific data were compromised and
what actions are required for forensic investigation and legal compliance.
POLICY GUIDELINES
Cornell Restricted Access Data Center (CRADC) is committed to compliance of restricted data.
For the purpose of this document, restricted data relates to any nonpublic data that is
protected by regulation, law or policy and/or is subject to contractual access restrictions as
defined by a Data Use Agreement (DUA). CRADC, as the Data Custodian of these data, along
with the authorized research team (Researcher), are obligated to adhere to the conditions set
forth by the Data Provider in a signed DUA and this policy.
Reporting:
It is the responsibility of the Researcher to contact CRADC’s Security Liaison in a timely manner,
in accordance with Cornell University Policy 5.4.2, Reporting Electronic Security Incident, if the
Researcher suspects or is aware of a compromise creating risk of unauthorized access to
restricted data.
Response:
Upon receipt of such report, the CRADC Security Liaison, the CRADC Secure Data Services
Manager, and the Sr. Systems Administrator will convene to review the report. Upon initial
review, the Cornell University Security Office will be notified to assist, according to Cornell
University Policy 5.4.2, Reporting Electronic Security Incident.
Process Steps:
1. Identify:
a. Nature of incident to best of knowledge
b. Identify data involved
c. Establish Data Provider contact information
d. Identify systems involved, remove from network if applicable
e. Review applicable policies, regulations and/or laws involved
2. Recovery and Response:
a. Contact Cornell University IT Security Office for assistance in forensics
b. Secure the system and preserve it without change
c. If deemed necessary, the Security Office will alert Cornell University Data-Loss
Incident Response Team
d. Resolve situation
3. Communicate:
a. Contact Office of Sponsored Programs
b. OSP will contact Data Provider to inform of current situation
c. If required, notify individuals of data theft
4. Document:
a. Create an incident report
b. Document lessons learned
c. Update necessary documentation
ENTITIES AFFECTED BY THIS POLICY
CRADC Secure Data Services Manager, CRADC Secure Data Specialist, CISER Information
Technology staff, and CRADC account holders.
WHO SHOULD READ THIS POLICY
CRADC Secure Data Services Manager, CRADC Secure Data Specialist, CISER Information
Technology staff, CRADC account holders and affiliated CRADC staff.
RELATED DOCUMENTS
Cornell University Policy 5.1, Responsible Use of Information Technology Resources
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/responsi
bleuse.cfm
Cornell University Policy 5.4.1, Security of Information Technology Resources
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/resource
s.cfm
Cornell University Policy 5.4.2, Reporting Electronic Security Incidents
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/incidents
.cfm
Cornell University Policy 5.8, Authentication to Information Technology Resources
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/authenti
cation.cfm
Cornell University Policy 5.9, Access to Information Technology Data and Monitoring Network
Transmissions
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/itdata.cf
m
Cornell University Policy 5.10, Information Security
http://www.dfa.cornell.edu/treasurer/policyoffice/policies/volumes/informationtech/infosecur
ity.cfm
CONTACTS
If you have questions about specific issues regarding this Sharing, Transmission and Distribution
of Restricted Data Policy, call the following offices:
William Block
Warren Brown
Stephanie Jacobs
Janet Heslop
block@cornell.edu
cradc@cornell.edu
cradc@cornell.edu
jheslop@cornell.edu
Kim Burlingame
Cornell University
Security Office
Kb269@cornell.edu
securityservices@cornell.edu
CISER Director
CRADC Secure Data Services Manager
CRADC Secure Data Specialist
CISER Director of Information Technology
and Security Liaison
CISER Sr. System Administrator
607-255-4081
607-255-4081
607-255-4081
607-255-4081
607-255-4081
607-255-6664
RESPONSIBILITIES
The following are major responsibilities each party has in connection with this policy.
CRADC Secure Data Services Manager
CISER Director of Information Technology
and Security Liaison
CISER Sr. System Administrator
CRADC Affiliated Staff
CRADC Researcher
Interpret this policy, provide clarification and
education, and implement operational and
business processes to facilitate compliance.
Implement operational, physical, and
technical equipment and tools to facilitate
compliance.
Responsible for performing tasks in
accordance with established policy
guidelines.
Responsible for knowing and assisting with
tasks as related to this policy.
Responsible for knowing and abiding by the
Data Provider Agreement and this policy.